Nature and Biodiversity Conservation Union (NABU)
During the participation in the EEG legislative process, NABU criticized the period of three years for piloting tenders with solar farms as too short for proper testing for suitability and efficiency. A set feed-in remuneration should always be kept for privately owned, small solar facilities with less than 1 megawatt capacity. The NABU lobbied to see environment-protection issues embedded in the EEG. Wind turbines and solar farms that are built in protected areas (also at sea) are now widely excluded from receiving feed-in remuneration. The association applauded the move to limit biogas development as this would avoid further maize monocropping.
Friends of the Earth, Germany (Bund für Umwelt und Naturschutz Deutschland – BUND)
The BUND criticises the growth corridor for renewables because it would slow down the development of solar and wind energy. Furthermore it considers the 30-per-cent-renewables-by 2020-target of the government too low as this would mean fossil fuels would replace some of the nuclear power, which is being phased out. Germany’s climate targets (40 per cent less greenhouse gas emissions by 2020) cannot be met if renewables development is curtailed, BUND says. According to the BUND, feed-in tariffs remain the best mechanism for promoting renewable energy. It fears that people will start questioning the benefits of the Energiewende if direct marketing and competitive bidding are implemented and participation of citizens in the green energy development starts to fade. Like the NABU, the BUND stresses the need to prevent building renewable facilities in protected areas and to limit the development of biogas plants that use maize.
In its response to the draft of the Renewable Energy Act 2014, Greenpeace bemoans that the new EEG is pushed through at high speed while adaptation of similarly important rules, such as the EnWG, regulating the electricity market and energy efficiency targets, are postponed. This leads to an incoherent system, which will require further changes to the EEG soon and which hurts investors’ trust in the Energiewende. Greenpeace suggests to amend the electricity tax, which is currently the same for power from coal, nuclear or renewable sources. Renewables should be exempt from the tax while conventional energies should be taxed more. The group points out that the discussion around the Renewable Energy Act has been reduced to a one-sided cost debate. Costs for the development of renewables are depicted as a burden instead of calling them an investment in the future.
Growth corridors: Greenpeace objects to growth corridors for renewables. They call them economically absurd because neither further development of wind power nor photovoltaics cause the EEG-surcharge to rise considerably. Greenpeace also argues that the caps are set too narrowly to allow renewable energy to replace the nuclear power plants, which are being phased-out. Germany and Europe might therefore miss their climate targets for 2020, the group warns. Greenpeace supports wind parks in areas where conditions are not ideal in order to allow their development all over Germany and to reduce the need for new grids.
Competitive bidding: Greenpeace opposes tenders for renewables for several reasons: a) they have not been successfully tested anywhere; b) they endanger the participation of small operators; c) they do not reduce the costs of the Energiewende; d) they often lead to unfinished projects and missed targets; e) they cause a lot of bureaucracy. The government’s approach of testing the tenders system on solar parks will not produce transferable results for wind energy projects as planning periods and investment costs of these two technologies are not comparable.
Self-supply: Operators of renewable facilities should not pay the EEG-surcharge on electricity they consume themselves, says Greenpeace. Operators of small power stations for factories should pay the EEG-surcharge as their exemption is not in agreement with European Law.
Mandatory direct marketing: Greenpeace says that direct marketing of renewables undermines the priority grid access that wind, solar and biogas enjoyed in all previous renewable energy bills.
Industry reliefs: Only companies that are verifiably energy intensive and are subjected to international competition should be allowed an exemption from paying the whole EEG-surcharge. The relief should also depend on energy efficiency requirements.